European Commission President Ursula von der Leyen announced that during the first 100 days of the new legislative period, three important acts on sustainability would be streamlined and simplified within a so-called "Omnibus" regulation: the Corporate Sustainability Due Diligence Directive (CS3D), the Corporate Sustainability Reporting Directive (CSRD), and the Taxonomy Regulation. The goal is to reduce duplicated and overlapping reporting obligations in these regulations. 

The Omnibus regulation is set to be presented on 26 February. The associations united within the Arbeitsgemeinschaft Mittelstand, including the German Chamber of Commerce and Industry, view this step positively. However, in a joint letter to representatives of the Commission, Members of the European Parliament, and other policymakers, they emphasize that this package must bring concrete relief to small and medium-sized enterprises (SMEs).

Against trickle-down effects and for trust

In the Omnibus regulation, the "indirect extension to exempted SMEs along the value chain" must be limited. Although non-capital market-oriented SMEs are fundamentally exempt from reporting obligations under CS3D, CSRD, and the Taxonomy Regulation, they are often asked by their business partners or banks to provide the information needed to fulfill their reporting, disclosure, and notification obligations (“trickle-down effects”). 

Additionally, the associations urge a "trust-based policy approach for SMEs" that reduces reporting obligations to the absolute minimum. The announcement by the European Commission to reduce bureaucratic burdens for SMEs by 35% is described as "an important and central signal" in the letter from the Arbeitsgemeinschaft. However, concrete measures that would provide actual noticeable relief to businesses are still lacking. "The announced Omnibus regulation must therefore be used to sustainably and noticeably reduce bureaucracy for SMEs." 

About the paper

Details on how these two demands could be specifically embedded in the new package can be found in the "Positionspapier Omnibus" of the Arbeitsgemeinschaft Mittelstand. It is available in PDF format at www.arbeitsgemeinschaft-mittelstand.de (only available in German).